Latest Technology - Mail Topics

We offer eStatements to customers, and send an email when the statement is available. Do we need to revert to paper statements in either of the two following situations? (1) If the email bounces back, (2) the customer does not access the e-statement? Do we increase our liability in any way if we do not monitor for either of these scenarios?

If a member is signed up for eStatements and the email notices bounce back for whatever reason do we have to deactivate the eStatement enrollment? Does it mean that we are not able to reach the member similar to returned mail statements?

We are getting ready to open accounts online. Do we require the signature card printed, signed, and returned to bank? Many banks do not. What are the legal concerns if we do not have a signature on file?

We offer e-statements to customers. When someone signs up, he is provided the Reg E disclosure electronically at that time. Do we need to have a link to the disclosure for future reference, and specifically, the Reg E part of reviewing a statement for errors? Would a link be sufficient for people to access at any time if the language is not included on each statement?

We are starting the process leading up to electronic statements. I asked that marketing offers be optional links. I would like compliance issues, such as notices of change, to be prominent either at the top of the statement page and/or appear automatically and require action on the part of the customer to move past the notice. I don't know yet what I will get. If we have the technology to obtain customer consent to receive electronic statements, I would think this would be a piece of cake. Of course, I am not a programmer. How are others handling this?

My question is related to PART 205—ELECTRONIC FUND TRANSFERS (REGULATION E) Section 205.17 Requirements for overdraft services. <i>(iv) Provides the consumer with confirmation of the consumer's consent in writing, or if the consumer agrees, electronically, which includes a statement informing the consumer of the right to revoke such consent.</i> For new accounts, will this requirement for confirmation be satisfied if the new account disclosures contain the appropriate language, or are we required to mail a separate confirmation to the customer who opts in after the fact?

We have a form available for customers to sign, who have access to Internet banking and online statements, if they wish to discontinue receiving paper statements in the mail. Is it necessary to have signatures of all signers, if it is a joint account? Can one account owner opt out of paper statements for a joint account?

Asking this question for both current and future rules:
On a construction-permanent loan application that has only one closing and one set of LE/CD disclosures for the transaction, what should the "sale price" be on the LE/CD with a transaction that involves a seller?
Should it only be the amount of the purchase price or should the cost to construct be included with the purchase price? I'm leaning towards the purchase price only based on 1026.37(a)(7) but we've been adding in the construction costs for some time now without criticism...

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